20251202Post Hearing Brief.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 9810
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-24-44
APPROVAL OF SPECIAL CONTRACT AND )
TARIFF SCHEDULE 28 TO PROVIDE ) COMMISSION STAFF'S POST-
ELECTRIC SERVICE TO MICRON IDAHO ) HEARING BRIEF
SEMICONDUCTOR MANUFACTURING )
(TRITON)LLC )
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its Attorney of record, Chris Burdin, Deputy Attorney General,
submits the following post-hearing brief.
BACKGROUND
On December 6, 2024, Idaho Power Company ("Company") filed an application
("Application") with the Idaho Public Utilities Commission ("Commission") requesting an order
approving the Special Contract for electric service between the Company and Micron Idaho
Semiconductor Manufacturing (Triton) LLC ("Micron"), for Micron's new memory
manufacturing fabrication complex ("Micron FAB"), and approving the rates proposed in tariff
Schedule 28.
On January 27, 2025, the Commission issued a Notice of Application and Notice of
Modified Procedure establishing a March 12, 2025, initial comment deadline, and a March 26,
COMMISSION STAFF'S POST-HEARING BRIEF
1 DECEMBER 2, 2025

2025,reply comment deadline. Order No. 36446. The Commission granted intervention to Micron
Technology, Inc. the Idaho Irrigation Pumpers Association, Inc. ("IIPA"), and the Industrial
Customers of Idaho Power("ICIP"). Order Nos. 36460, 36479, 36483.
On February 20, 2025, IIPA filed an Objection to Modified Procedure, Demand for
Hearing, and Motion to Consolidate for Hearing with Interrelated Cases ("Motion"). IIPA
requested oral argument on the Motion. After hearing oral arguments, on April 15, 2025, the
Commission issued Order No. 36547 granting in part and denying in part IIPA's Motion.
On July 15, 2025, the Commission issued a Notice of Schedule and Notice of Technical
Hearing. Order No. 36689. On October 28, 2025, the Commission held a Technical Hearing. On
November 20,2025,the Commission issued a Notice of Briefing Schedule and Notice of Deadline
to Request Intervenor Funding. Order No. 36853.
STAFF POSITION
After participating in the October 28,2025,technical hearing, and reviewing the submitted
materials from all parties, Staff continues to recommend that the Commission approve the
proposed Special Contract contingent on modifications to the contract terms related to: (1) the
Marginal Cost-Based Energy Charges; and(2) the Minimum Monthly Billing Demand, as outline
in Staff s submitted testimony.
Staff also recommends that the Commission approve the Company's proposed method for
determining the Marginal Cost-Based Energy Charge and the proposed method for determining
the Demand Charges, and order the Company to update the Energy Charge and Demand Charges
included in the proposed Schedule 28 tariff through a compliance filing.
Staff recommends that the Commission approve the PCA accounting treatment proposed
in the Application.Additionally, Staff continues to recommend that the Company isolate the effect
of new special contract customers when cost allocation and rates need to be set for these customers
in future general rate cases. Staff believes the Company should develop methods to ensure other
customers are not harmed by the inclusion of new large loads onto the system.
Due to the magnitude of risk associated with the Micron Fab contract, Staff supports any
additional steps or conditions to minimize risk to other customers, and Staff believes it is up to the
COMMISSION STAFF'S POST-HEARING BRIEF
2 DECEMBER 2, 2025

Commission to determine what is fair and reasonable for each risk mitigation item. Staff believes
the risk mitigation items in the contract should at a minimum: allow changes to the marginal cost
method with justification; allow rate components to change and the methods for determining the
rate components to change; include extended take or pay provisions providing that any changes to
the reduction of minimums be justified; include termination payments and any additional
protections for termination payments; and allow changes to embedded energy rates with
justification.
Respectfully submitted this 2nd day of December, 2025.
_L ,��,A
Chris Burdin
Deputy Attorney General
IALegahELECTRIC\IPC-E-24-44_Triton\IPCE2444_Staff PHB_cb.docx
COMMISSION STAFF'S POST-HEARING BRIEF
3 DECEMBER 2, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2ND DAY OF DECEMBER 2025, SERVED THE
FOREGOING COMMISSION STAFF'S POST-HEARING BRIEF,IN CASE NO. IPC-E-24-44,BY E-
MAILING A COPY THEREOF,TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNER
DONOVAN E.WALKER GRANT ANDERSON
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
maoicoecheaallengidahopower.com caschenbrenner(&idahopower.com
dwalker(a)idahopower.com ganderson(a6dahopower.com
dockets(&idahopower.com
Micron Micron
AUSTIN RUESCHHOFF AUSTIN W JENSEN
THORVALD A NELSON KRISTINE A.K.ROACH
HOLLAND&HART LLP HOLLAND&HART LLP
555 17TH ST STE 3200 555 17TH ST STE 3200
DENVER CO 80202 DENVER CO 80202
darueschhoff(a)hollandhart.com awjensen a,hollandhart.com
[e-mail] [e-mail]
[e-mail]
Idaho Irrigation Pumpers Assn,Inc. Idaho Irrigation Pumpers Ass'n,Inc.
Eric L. Olsen Lance Kaufman,Ph.D.
Echo Hawk&Olsen,PLLC 2623 NW Bluebell Place
P.O.Box 6119 Corvallis,OR 97330
505 Pershing Ave., Ste. 100 lance(&aegisinsi h
Pocatello,ID 83205
elo(a)echohawk.com
Industrial Customers ofldaho Power Industrial Customers ofldaho Power
Peter J.Richardson Dr.Don Reading
Richardson Adams,PLLC 280 S. Silverwood Way
515 N.27t'St. Eagle,ID 83716
Boise,ID 83702 dreading&a,mindsprin_ com
[e-mail]
Clean Energy Opportunities for Idaho Clean Energy Opportunities for Idaho
Kelsey Jae Courtney White
920 N. Clover Dr. Mike Heckler
Boise,ID 83703 Clean Energy Opportunities for Idaho
kelsey(&kelseyjae.com 3778 Plantation River Dr., Ste. 102
Boise,ID 83703
courtneygcleanenergyopportunities.com
mikekcleanenergyopportunities.com
Keri J. H wker
Legal Administrative Assistant
COMMISSION STAFF'S POST-HEARING BRIEF
4 DECEMBER 2, 2025